Recently, the long-awaited Fluorine-Free Foam (F3) military specification (MilSpec) was released. The creation of this specification was the result of a multi-year effort to develop a performance standard for F3 so that a transition away from the use of aqueous film-forming foam (AFFF) containing per- and poly-fluoroalkyl substances (PFAS) could occur. The F3 MilSpec lists the performance and composition requirements for F3 products that must be followed by Part 139 airports concerning the use of firefighting foam at their facilities.
There are noteworthy differences between AFFF MilSpec and the new F3 MilSpec. The most notable include:
- Compliant F3 must test “non-detect” for PFAS and manufacturers must certify in writing that “PFAS has not intentionally been added to the concentrate.”
- “Fluorine-free” is defined as a concentrate that contains a maximum of 1 part-per-billion (ppb) PFAS. This has been included because, although not expected, there is a very slight possibility that a byproduct of PFAS could occur as part of the manufacturing process. It is anticipated that F3 manufacturers meeting the MilSpec will be offering compliant F3 products that do not contain a byproduct of PFAS.
- The fire extinguishment and burnback time performance requirements of F3 are different than AFFF. The requirements for F3 are based on new factors like different types of fuel used for the performance test fire, concentration of F3 used in the foam/water mixture, and the age of the F3 concentrate. In summary, the length of time in which F3 must be able to contain a fire after it is applied is less than for AFFF.
- The MilSpec notes that as the military and contractors gain experience about the performance of F3, the requirements established in the MilSpec may change.
The FAA also released CertAlert 23-01 to inform Part 139 airports about the new F3 MilSpec and to provide information on next steps concerning the use of F3 at their facilities. Highlights of the CertAlert include:
- The FAA will allow airports to use F3 once products have been identified on the military’s Qualified Product List (QPL).
- The FAA will not require airports to transition to F3 and will still allow the use of AFFF to meet Part 139 fire extinguishing agent requirements.
- The FAA anticipates it will take a minimum of 90 to 120 days from the issuance of the MilSpec before the F3 product certification process is complete.
- Airports should plan for possible delays in distribution and delivery of F3. This is because the initial supply of F3 may be limited since both Part 139 airports and the military will have an immediate interest in purchasing.
In summary, now that the F3 MilSpec has been published, the next step before Part 139 airports can use F3 is for the military to conduct performance testing and list compliant products on the QPL. This is anticipated to occur by May 2023, and while no information has yet been made publicly available, it is believed that there are at least three current products that can meet this specification. This testing will also include an environmental, safety, and occupational health evaluation by the Army Public Health Center.
Though the release of the F3 MilSpec is an important step in Part 139 airports being able to transition away from the use of AFFF containing PFAS, they will not yet be able to use F3 until the QPL product list is published. Airports are encouraged to continue to monitor industry channels for updates about the progress of F3 performance testing and the anticipated timing of the release of the F3 QPL.
